In a federal criminal case, the Fifth Circuit addressed whether a conviction under Florida's manslaughter statute qualified as a crime of violence under the federal sentencing provisions.  It found that it did not.  In doing so, it noted two things that are valuable to immigration practitioners: 1) It does not require the infliction of violent force (making it unlikely to be a crime of violence under 18 USC 16 (a); and 2) It criminalizes reckless conduct (which, in some circuits, will be a good argument that it is not a crime of violence under 18 USC 16(b) either).


The full text of US v. Garcia-Perez can be found here: